Last Updated: September 15, 2020
If you apply for a loan, we will provide you with a separate notice, entitled “What Does Transform Credit Do With Your Personal Information?” (the “Notice”) which describes our policies with respect to the use, maintenance, and disclosure of the non-public PII about you that we obtain in connection with offering to you or providing you with a financial product or service to be used primarily for personal, family, or household purposes. To the extent that there is any conflict between this Policy and the Notice, the Notice will control.
Please read this Policy carefully. By using our Site or Services, you agree to our collection, use, and sharing of your PII as described in this Policy.
Not all information that we collect from or about you (“Your Information”) is PII. In general, the information you affirmatively provide to us, such as when you seek information from us or fill out an application form, will be PII. But we also automatically collect information from your computer or other device that you use to connect with our Sites that we cannot use to identify you specifically. Listed below are the types of information about you that we may have collected within the past 12 months. These types of information are PII only if the information identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.
Some of the information about you or your device is collected through cookies and other tracking technologies on our Site. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. The cookies we use include session cookies, which make it easier for you to navigate our Site (these are created each time you visit the Site and expire 24 hours after that visit), and persistent cookies, which remain on your hard drive for an extended period of time. Persistent cookies enable us to track and target the interests of our users to enhance the experience on our Site. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.
If you reject cookies, you may still use our Site, but your ability to use some areas of our Site may be limited. For example, you may be unable to take out a loan or other product without accepting cookies. We may use a software technology called tracking pixels (a.k.a. web beacons or clear gifs) that help us better manage content on our Site by informing us what content is most effective. Tracking pixels are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, tracking pixels are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may also use other website or mobile tracking technologies, such as device fingerprinting, to identify you and keep track of your preferences, prevent fraudulent activity or improve Site security, assess the performance of the Site, and deliver content to you based on your interests on our site and third-party sites.
We may use the PII we collect from or about you, for a variety of purposes permitted by law, including:
We reserve the right to share the PII about you that we collect as described below:
Other than for these purposes, we do not share PII with third parties and in no event do we sell PII. We do not share PII with non-affiliated entities for those entities to use for their own marketing purposes.
If you apply to be or are a customer of Transform Credit, we provide you with certain “opt-out” rights from having your PII used or shared for certain purposes. For more information regarding your rights related to our sharing of your non-public personal information, please refer to the Notice that we will provide to you if you apply for a loan or, contact us using the methods described at www.TransformCredit.com/Contact.
If your PII changes, or if you no longer desire our Services, you may correct or update your PII by contacting us at: 470-435-6300 or hello@transform credit.com. If you have an account with us and your account is in good standing, you may also correct or update your PII by logging into to your account on our Site and updating your information there.
The security of your PII is important to us. We maintain reasonable physical, technical, and administrative security measures to protect and limit access to your PII. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security. If you have any questions about the security on our Site, you can contact us at 470-435-6300.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Some of these third parties may provide you with ways to choose not to have your information collected or used for targeted advertising.
The Site may contain links to or links from third party sites that are not owned or controlled by Transform Credit Inc. We have no control over the content, privacy policies, or practices of any third party site. You are subject to the policies of those third party sites where applicable. We encourage you to review the privacy policies of these third party sites before you disclose your PII.
The Site is not currently configured to respond to Do-Not-Track signals.
Our Site and Services are not intended for use by children. We do not knowingly collect personal information from children under the age of 13 years. If we become aware that a child under 13 has opened an account or otherwise provided us with PII, we take steps to terminate the child’s account and delete such PII. If you believe that we have inadvertently received any such PII, please contact us at 470-435-6300.
If you are a resident of California, you have certain privacy rights under the California Consumer Privacy Act (“CCPA”). We honor those rights, as described below, and we are prohibited by law from discriminating against you for exercising any of those rights.A. Right to Know
Subject to the exemptions mentioned below in part X(C) below, if you are a California resident, you have the right to know what PII we have collected about you, why we collected it, and the categories of third parties (excluding service providers) with whom we have shared the PII during the past 12 months. (See below on “How to Submit a Request.”) You may request that we provide a description of the categories of PII we have collected (a “Categories Request”) or a request for access to the specific pieces of PII we have collected (a “Specific Pieces Request.”)
If you make a Categories Request, and you do not have any type of account with us, we will need you to provide us with at least two data elements specific to you, such as your cell phone number or mother’s maiden name (depending on the data elements we already maintain about you), so that we can verify your identity. After we confirm that your request is a verifiable consumer request, we will disclose to you:
If you make a Specific Pieces Request, we need to be sure we have verified your identity with great certainty to safeguard your privacy. In order for to verify your identity, if you do not have any type of account with us, you will need to provide to us at least three data elements specific to you, together with a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If we are able to confirm that your request is a verifiable consumer request, we will provide you with copies of the specific pieces of PII we collected about you that you requested.B. Right to Request Deletion
You have the right to request that we delete any of your PII that we collected from you and retained, subject to the exemptions described in Part X(C) below. We are not obligated to comply with your request if we have a legal basis to retain the PII. If you make a request for us to delete PII, and you do not have any type of account with us, we may need you to provide us with at least two data elements specific to you so that we can verify your identity. Once we receive and confirm that your request is a verifiable consumer request (see below on “How to Submit a Request”), we will inform you whether we have deleted (and have directed our service providers to delete) your PII from our records, or whether we are declining to grant your request to delete due to an exception to the CCPA deletion requirements.C. Exemptions
Certain PII is protected by federal and state privacy law other than the CCPA and thus the specific rights described above do not apply in the case of that PII. Specifically:
To request access to or deletion of your PII as described above, please submit a verifiable consumer request to us by:
Sending your request to: firstname.lastname@example.org
You may make a request on your own behalf, and if you are the parent or guardian of a minor child, you also may make a request related to your child’s PII. If you wish to designate an authorized agent to make a request on your behalf, please provide us with a signed declaration stating that your intent is to permit that individual to act on your behalf and include such individual’s full name, address, email address, and phone number. That way we will be sure you have fully authorized us to act in accordance with the requests of that individual.
In order to protect your PII from unauthorized disclosure or deletion at the request of someone other than you or your legal representative, Transform Credit requires identification verification before granting any request to provide copies of, know more about, or delete your PII. Specifically, we require that any request submitted to us:
We cannot respond to your request or provide you with PII if we cannot verify your identity or authority to make the request and confirm that the PII relates to you.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing. We will only use PII provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
This Site is based in the United States and is subject to U.S. law. This Site is controlled, operated, and administered by Transform Credit Inc. from its offices within the United States. If you are accessing this Site from a location outside the United States, you hereby consent to the collection of our PII in the United States, whose privacy laws may be less protective than those of the jurisdiction where you are located.
We reserve the right to modify this Policy at any time, so please review it frequently. If we decide to make material changes to this Policy, we will post those changes to this Site in a manner that we deem is appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. You agree to these future updates by continuing to use our Site or Services after they have been posted. You can always obtain a copy of the most updated Policy by reviewing this Site.